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Comments by Dedham Vale Society on Dedham Vale AONB etc. Management Plan

The AONB Management Plan is a statutory requirement, involving the relevant County and District Councils, Natural England, Environment Agency, and many others. It is, the official guidance makes clear, meant to be “much more than a guide for the activities of an AONB staff unit” (page 17). The strategy element should be “an ambitious visionary statement” (page 6). The policies of the relevant local authorities “need not be confined to those aspects they can deliver themselves” (page 75). “Some policies may need to extend beyond the AONB boundary” (page 22). And so on.

The draft Dedham Vale AONB etc. Management Plan (“the draft Plan”) does aim to provide both the visionary strategy for the AONB to 2025 and the action plan for the AONB staff unit to 2014. While the Dedham Vale Society (DVS) accepts that the draft plan does aim to provide both a visionary strategy for the AONB to 2025 and an action plan to 2014. DVS considers that the strategy lacks specifics, particularly in relation to the AONB, and the action plan is almost entirely restricted to the activities of the project staff unit. DVS has the following suggestions for sharpening the plan:

  1. The Traffic & Transport Theme Vision for 2025 should be much more specific, as at the 1st attachment. This applies just to the AONB: it would need to be adapted to apply to the rest of the Project area.
  2. Climate change merits more explicit discussion, as at the 2nd attachment.
  3. Preventing mass tourism “killing the thing it loves” needs more consideration.
  4. Consideration should be given to establishing the concept of “Gainsborough’s Country”. It is a myth that all Gainsborough’s landscapes, unlike Constable’s, were imaginary. Some known counter-examples in the Project area are at Bulmer (Mr & Mrs Andrews), Abbas Hall (Cornard Wood), Lamarsh and Clare. Others might well emerge with research. Working with the one serious art-historical resource in the area, Gainsborough’s House, could help develop a useful counter-magnet to Dedham/Flatford.
  5. The Plan should be reviewed in light of the just-published Pretty Report (the Essex Rural Commission). The conclusion may well be that its recommendations are not all appropriate for the AONB – eg DVS strongly disagrees with its views on rural affordable housing – see our 2nd attachment, point 3 – but it needs careful consideration, and in many instances adds weight to the AONB Plan.
  6. All public bodies and statutory undertakers operating in the AONB should be invited to spell out how they are fulfilling their statutory objectives under the Countryside and Rights of Way Act 2000, section 85 . See points 6 and 7 below.
  7. Provision should be made for working with other AONB staff units on common issues (such as traffic calming, sat navs, CRoW 2000 s85)
  8. Constable Country is too narrowly defined, excluding for example Stoke by Nayland and Stratford St Mary, both sites of major pictures by the artist (Theme 1, 1.12.3.3. last para and again at 1.14.1 third para)
  9. On Utility infrastructure: the Plan should aim not merely for the removal of redundant infrastructure (Action 15.2), but also for continuing infrastructure eg mobile phone aerials to be hidden.
  10. On Undergrounding (low-voltage electricity and telephones): the Plan should not merely plead for undergrounding (Action 14.3) but identify and prioritise all the undergrounding needed in AONB. It should flag up need to underground in villages (outside OFGEM scheme). It should aim to research, with others, why undergrounding seemingly costs so much less in other countries eg France.
  11. On Bio-diversity: with landowners, the Plan should aim to create “green infrastructure” links between river/woods/parks/golf course.
  12. Concern has been expressed to us that the DVS Project should seek to protect the farmers' ESA. Apparently if the farmers lose this status they will plough the grasslands of the Vale and plant wheat. We ask that this be looked into, and suitable action included in the Plan.

The 3rd attachment notes some detailed points.


1 Countryside Agency’s Guide to AONB Management Plans, available at http://naturalengland.etraderstores.com/NaturalEnglandShop/product.aspx?ProductID=0d1fc619-dede-4f5d-907c-970f3e223df0

2 This provides that In exercising or performing any functions in relation to, or so as to affect, land in an AONB, [all public bodies and statutory undertakers] shall have regard to the purpose of conserving and enhancing the natural beauty of the AONB



 

Attachments relating to the above

 

1st attachment: Suggested 2025 vision for Traffic & Transport

  1. 40 mph limit on B1029, B1068 and B1087 outside villages
  2. 40 mph limit on other secondary roads (“brown roads” on 1 : 25,000 scale Ordnance Survey (OS) maps) outside villages
  3. Self-enforcing 20 mph speed limits on all minor roads (“yellow roads” on 1 : 25,000 scale OS maps) and in all villages. “Self enforcing” measures (eg raised platforms, sharp bends) to have no adverse effects on amenity (other than vehicle drivers’).
  4. Roads as at 3, excluding B1029 through Dedham and B1068 & B1087 through Stoke, Thorington Street & Higham to be “shared space”, ie where motor vehicles accommodate to pedestrians, cyclists, horses etc. (as well as to motor vehicles).
  5. Where current footpaths end on roads with speed limit above 20 mph, links to be provided that connect to other pedestrian-friendly routes
  6. Cycle-friendly routes for all journeys between villages
  7. Pedestrian-friendly routes for all journeys within villages
  8. Juggernauts confined to A12 and A134 except for necessary access. “Necessary access” to be controlled, and activities requiring juggernaut access to be relocated as and when practicable (ie excluding farms). “Juggernaut” definition to start high, eg four or more axles including trailer, and come down over time.

It is recognised that the DV AONB & SV Project cannot bring these things about on its own. But it can help bring them about, by eg

  • Publicly endorsing and publicising the objectives
  • Lobbying for those within the gift of the Highways Authorities/police at negligible cash outlay (1 and 2)
  • Monitoring and publicising their attainment (eg which yellow roads are effectively shared space with self-enforcing 20 mph limits? Which footpaths end on pedestrian-hostile roads? What proportion of juggernauts is not for necessary access?)
  • Advising Parish Councils on suitable traffic-calming measures
  • Locating non-standard funding sources for traffic-calming measures
  • Analysing, critically, the demands for juggernaut access
  • Helping design and negotiate new walking and cycle routes
  • Sponsoring walking and cycling maps that take account of permissive paths and suitable yellow roads (ie unlike OS maps).
  • Working with other AONBs, and National Parks, on common concerns. For example, the Dartmoor National Park is permitted to sign speed limits by signs on the road surface only, with no obtrusive road side signs.

Anyway, the AONB Management Plan is meant to be “much more than a guide for the activities of an AONB staff unit” (see opening paragraph of main text).


 

2nd attachment: Suggested 2025 vision for Climate change

We consider the need to address this has radical, and generally positive, implications for the AONB. Its implications merit being dealt with much more explicitly than in the draft Plan – see 2 and 3 below. But we do not agree that it should become the dominant criterion – see 1 below.

  1. Transition Town status for the AONB (Action A13.2). We consider it wrong for a body concerned with amenity to adopt non-amenity objectives. Climate change is important, but it is not what the AONB is for. Obviously AONB management must comply with government and legal obligations in the climate change area as all others. Often climate change considerations point in the same direction as amenity considerations – see 2 and 3 below. But none of this justifies a body concerned with amenity in adopting non-amenity objectives. We know, after all, that not all climate change initiatives are consistent with the AONB. One example is large-scale windpower. Commercial-scale bio-mass farming for generation of electricity or liquid fuels would probably be another.
  2. Spatial planning: The AONB Plan should emphasise that the crucial carbon footprint objective for spatial planning is locating development of every kind, industrial, commercial, public sector and residential, so as to minimise transport mileage. In northeast Essex and southeast Suffolk, this means that all significant development should be located in Colchester or Ipswich, at Felixstowe or Harwich, by an A12 or A14 junction or alongside the Great Eastern mainline. That is, on carbon footprint grounds alone, no development which is capable of taking place elsewhere should take place within the AONB. NB the “climate change”, “sustainability”, “carbon footprint” agenda is required to be central to Planning Authorities’ Local Development Frameworks.
  3. Housing: The AONB Plan should emphasise that significant additional housing is incompatible with preserving the character of the AONB, and incompatible with climate change objectives as at 2 above. However desirable it may be to provide affordable housing in rural areas for people working there, there are insuperable legal/financial/institutional obstacles to (a) ensuring such housing remains affordable; (b) ensuring such housing remains occupied by people with a local connection. In particular, Rural exceptions sites for “Affordable Housing”, ie sites outside village envelopes, have no place in an AONB.


3rd attachment: points of detail

  1. “affects” for “effects”, 1.12.3.5 second para
  2. “negative effect and careful consideration is required when them.” 1.13.3.3 last para
  3. “There are issues of commuter It is recognized” “…not usually in itself a problem but the problems caused by congestion…” (both 1.16.3.4)
  4. The Vision Statement uses the expression “working landscape” without really defining what “working” means.
  5. The maps are largely unreadable.
  6. “In 2025 the people of the Dedham Vale AONB and Stour Valley community understand the importance of the area that they live in” (Theme 2, 1.13.2 first para). Do they not now?
  7. “In general, the design and location of new buildings has taken into account the character of the area.” This use of the phrase “in general” in a vision statement is alarming. It accepts that not all buildings will when surely the vision ought to be that all will. (Theme 2, 1.13.2 last para).
  8. “Many of the villages in the area are accessible by bus although services have a restrictive timetable” (Theme 5, 1.16.1. fourth para). Should “restrictive” be “restricted”?
  9. The list of abbreviations on pages 90 and 91 should be at the start not end of the Delivery Plan to act more helpfully as a guide to the perplexed.